The Penthouse contest rules

NO PURCHASE OR PAYMENT OF ANY KIND IS NECESSARY TO ENTER OR WIN. HOLDING, BUYING OR SELLING $TOWER DOES NOT IMPROVE YOUR CHANCES OF WINNING. VOID WHERE PROHIBITED OR RESTRICTED BY LAW.

1. The Contest

"The Penthouse" (the Contest) is a free, ongoing daily game-of-skill contest played in the PONZI TOWER browser game at ponzitower.com (the Game). Each day, the eligible player whose tower reaches the most floors holds the Penthouse and receives the rent described in section 8 while they hold it.

PONZI TOWER is satire. The companies, investors, loans and in-game cash (¤) in the Game are fictional. In-game cash is points: it has no value, cannot be bought, and cannot be redeemed. The Penthouse rent in section 8 is the only real-world prize connected to the Game.

2. Sponsor

The Contest is sponsored by [SPONSOR LEGAL NAME], [SPONSOR ENTITY TYPE AND JURISDICTION], [SPONSOR ADDRESS] (the Sponsor). Contact: [SPONSOR EMAIL]. "PONZI TOWER Holdings" is a fictional company in the Game and is not the Sponsor.

The Contest is not sponsored, endorsed or administered by, or associated with, Pump.fun, DEX Screener, X, Cloudflare, any wallet provider, or any company named or depicted in the Game.

3. Contest period

• The Contest runs in daily periods. Each period starts at 00:00:00 UTC and ends at 23:59:59 UTC on the same calendar day (a Contest Day).
• The first Contest Day is 2026-09-28, starting when the Sponsor announces that the Contest is open.
• The Contest continues daily until the Sponsor ends or suspends it under section 13.
• The Sponsor's servers are the official clock.

4. Eligibility

To be eligible you must, at the time of entry and of any payout:

1. be at least 18 years old or the age of majority where you live, whichever is higher [LAWYER TO CONFIRM];
2. not live in, be located in, or be a national of an Excluded Jurisdiction listed in section 5;
3. not be a person or entity on any sanctions list that the Sponsor is required to observe [LAWYER TO CONFIRM: which lists, e.g. OFAC SDN, UK, EU, UN];
4. not be an employee, contractor, officer or director of the Sponsor, or a member of their immediate family or household [LAWYER TO CONFIRM scope], and not enter using any wallet on the Sponsor's team list;
5. control the Solana wallet you sign in with, and be able to receive the Solana token described in section 8.

You are responsible for making sure that taking part is lawful where you are. Using a VPN or other means to hide your location is prohibited and is grounds for disqualification.

5. Excluded Jurisdictions

[LAWYER TO CONFIRM. Placeholder list; nothing below is a legal conclusion.]

• [JURISDICTION] ([REASON, e.g. restrictions on prize contests, skill-game laws, or sanctions])
• [JURISDICTION] ([REASON])
• [JURISDICTION] ([REASON])
• Any jurisdiction subject to comprehensive sanctions that the Sponsor must observe [LAWYER TO CONFIRM].
• Any jurisdiction where the Contest, or receiving the prize, would be unlawful.

The Sponsor may use IP-based and other checks to enforce this section [LAWYER TO CONFIRM whether geoblocking is required, and how].

6. How to enter (free)

1. Go to ponzitower.com/play/.
2. Sign in with a Solana wallet by signing a text message ("Sign in to claim the Penthouse"). Signing in never asks for a transaction, a payment, or access to your funds. Creating a wallet is free.
3. Pass the human check (Cloudflare Turnstile) when asked.
4. Play an online run. A run is eligible (an Eligible Run) only if it:
   • is started while you are signed in and after passing the human check;
   • is played online with the Sponsor's servers: the server generates a secret seed, deals the cards each quarter and enforces real-time quarters;
   • is completed (the tower falls) and recorded by the server during the Contest Day;
   • is not marked "offline", and is not disqualified under section 10.

You may play as many runs as you like, subject to the Game's rate limits. Each Eligible Run is an entry. Holding $TOWER is not required, and it does not affect your score or your chances.

Entry via a player's own automated methods, scripts or bots is not allowed (section 10). If you cannot or do not wish to use the Game's online sign-in, [LAWYER TO CONFIRM whether an alternative method of entry is required, and what it is].

7. Scoring and the Penthouse holder

• Score: the peak floors reached in the run, as recorded by the server. Valuation, lifespan and other statistics don't count.
• The Penthouse holder at any moment of a Contest Day is the wallet that submitted the highest-scoring Eligible Run completed so far that day.
• Tie-break: if two or more Eligible Runs have the same score, the one completed first, by server timestamp, ranks higher.
• At 00:00:00 UTC the Penthouse is vacated and the new Contest Day starts with no holder.
• Records: the current holder (tower name, shortened wallet, score, since when) and every payout are shown at ponzitower.com/penthouse. The server's records are final, subject to section 10.

8. The prize: Penthouse rent

• What it is. Five percent (5%) of the creator fees generated by trading of the $TOWER token on Pump.fun goes to a public Sponsor-controlled wallet, the Penthouse Vault [PENTHOUSE_VAULT]. This routing is fixed on-chain by Pump.fun's fee-sharing feature. The prize is whatever the Penthouse Vault holds when each payout is made.
• Asset. Paid in the BTC token used as the $TOWER trading pair on Pump.fun: a wrapped BTC token on the Solana blockchain (mint [BTC MINT]). It is not bitcoin on the Bitcoin network.
• Value. The amount depends entirely on trading activity. It varies, may be very small, and may be zero. The Sponsor does not guarantee any minimum amount or value. [LAWYER TO CONFIRM how to state an approximate retail value for a variable prize, if required.]
• Cadence. Every 15 minutes (a Tick), the Sponsor's payout program sends the Penthouse Vault's balance to the wallet of the Penthouse holder at that Tick.
• No holder. If there is no Penthouse holder at a Tick (for example just after midnight UTC), nothing is paid and the balance carries over to the next Tick.
• Minimums. Amounts too small to send economically may be carried over to a later Tick. [SPONSOR TO CONFIRM the Penthouse minimum, if any]
• Fees and accounts. The Sponsor pays the Solana network fees for payouts and, where needed, the cost of opening a BTC token account for the winner.
• Start of payouts. Payouts start only after the Sponsor completes a test of the payout program and announces that payouts are live. Until then, rent accumulates in the Penthouse Vault and is paid out at the first live Tick to the holder at that Tick.
• Finality. Payouts are on-chain transfers and are final once sent. Each payout is listed with its transaction signature on ponzitower.com/penthouse and ponzitower.com/rent.
• The prize is not transferable or exchangeable by the Sponsor for any other prize or for cash.

9. Winners' payment wallet

The prize is paid to the wallet you signed in with for the winning run, and only to that wallet. The Sponsor cannot reverse a payment sent to a wallet you no longer control.

10. Fair play, anti-cheat and disqualification

The following are prohibited:

• bots, scripts, automation or input macros;
• modified clients;
• tampering with network traffic or the Game's API;
• exploiting bugs;
• collusion;
• using multiple wallets or identities to get around rate limits or rules;
• entering from an Excluded Jurisdiction;
• any conduct the Sponsor reasonably believes undermines the Contest's fairness.

The Sponsor may, at its reasonable discretion:

• void any run or entry;
• disqualify a wallet or person, temporarily or permanently;
• stop any future payment to them;
• recalculate the Penthouse holder from the remaining Eligible Runs.

Payouts already sent are final on-chain. The Sponsor may request their return where the law allows [LAWYER TO CONFIRM].

Team wallets are excluded automatically. The Sponsor keeps server logs of every Eligible Run (seed, actions, timings) and may review them.

If a technical failure affects the Contest, the Sponsor may:

• pause payouts;
• void affected runs;
• carry the balance over.

Examples of such failures: server errors, network outages, blockchain congestion, payout program faults or wallet compromise.

11. Taxes and verification

• Winners are solely responsible for any taxes on prizes they receive.
• The Sponsor may require information from a winner (for example identity, residence, age or tax forms) before or after a payout, and may withhold payouts until it is received, where required by law or reasonably needed to enforce these rules. [LAWYER TO CONFIRM: tax reporting thresholds and any identity or KYC requirements for pseudonymous wallet winners in each permitted jurisdiction.]

12. Privacy and publicity

• What the Sponsor processes:
  • your wallet address;
  • the tower name and any X handle you choose to provide;
  • run records (seed, actions, timings, results);
  • a one-way hash of your IP address;
  • the result of the human check;
  • basic technical logs.
• Why: to operate the Game and the Contest, prevent cheating, and make payouts.
• What is public: your tower name, shortened wallet address, score and payouts. Blockchain transactions are public by nature.
• Publicity: the Sponsor will not post your X handle without your agreement.
• See the privacy policy at [PRIVACY POLICY URL] [LAWYER TO CONFIRM: GDPR/UK GDPR/CCPA disclosures, retention periods, data controller identity].

13. Changes, suspension and termination

The Sponsor may change, suspend or end the Contest, or these rules, at any time. For example: for legal reasons, security incidents, cheating or technical failures.

Changes are posted at ponzitower.com/rules with a "last updated" date and apply from then on. Payouts already sent are not affected. Any balance in the Penthouse Vault when the Contest ends will be [SPONSOR TO DECIDE: paid to the last holder / paid at a final Tick / other; LAWYER TO CONFIRM].

14. Limitation of liability and release

[LAWYER TO DRAFT: release, limitation of liability, no warranties for the Game or the payout program, force majeure, the risks of blockchain assets (including volatility and loss of access to wallets), indemnity.]

15. Disputes and governing law

[LAWYER TO DRAFT: governing law, venue or arbitration, class-action waiver if appropriate, and how disputes about the Penthouse holder are raised (e.g. email to [SPONSOR EMAIL] within 7 days of the Contest Day).]

16. Relationship to the token

The Contest is separate from any purchase or holding of $TOWER:

• Entry is free.
• Holding $TOWER doesn't help you win.
• The Contest is not an investment.

$TOWER is a memecoin with no intrinsic value or expectation of financial return. PONZI TOWER is a game; in-game cash has no value and cannot be redeemed. Not financial advice.

Last updated: [DATE] · Version 0.1 (draft)